# Finance Act 2025, Paragraph 12: Use of substituted values

Extent: E+W+S+N.I.

(1) After section 137 insert—
“Use of substituted values
137A (1) Where any provision of this Part requires the substitution of a value recorded in the underlying profits accounts of a member of a multinational group for an accounting period, the substituted value—
(a) is to be used for all purposes of this Part instead of the value recorded in the accounts (for example, where the carrying value of an asset has been substituted and the value of that asset is relevant to the member’s deferred tax expense, that substituted value is to be used in connection with determining that expense), and
(b) is to be updated (for example, in making adjustments for depreciation for subsequent accounting periods),
in each case, in accordance with the accounting standard used in determining the underlying profits of the member.
(2) But where the value in question is the value of an asset, no adjustments for impairment are to be made to it.
(3) Where the impaired value of an asset recorded in the underlying profits accounts for any accounting period is less than the substituted value of the asset for that period, use the value from the underlying profits accounts instead for that period and all subsequent periods (and subsection (2) does not apply in relation to that value).”
(2) In section 197 (eligible tangible asset amount), in subsection (3)—
(a) after “means” insert “values”, and
(b) after “parent” insert “(and not values as substituted as a result of any other provision of this Part)”.

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Source: https://www.legislation.gov.uk/ukpga/2025/8/schedule/4/paragraph/12 (the official version)
Page: https://openlegislation.uk/finance-act-2025/schedule-4/paragraph-12
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.